1904.0

Question 1

Why are employers required to keep records of work-related injuries and illnesses?

Answer 1

• OSHA collects data through the OSHA data iniative program to help direct its programs and measure its own performance
• The records are also used by employers and employees to implement safety and health programs at individual workplaces
• The records provide the base for the BLS SOII program

Question 2

What is the effect of workers’ compensation reports on the OSHA records?

Answer 2

The purpose section of the rule includes a note to make it clear that recording an injury or illness neither affects a person’s entitlement to workers’ compensation nor proves a violation of an OSHA rule.The rules for compensability under workers’ compensation differ from state to state and do not have any effect on whether or not a case needs to be recorded on the OSHA 300 Log. Many cases will be OSHA recordable and compensable under workers’ compensation. However, some cases will be compensable but not OSHA recordable, and some cases will be OSHA recordable but not compensable under workers’ compensation.

Question 3

What partial exemptions exist for employers with 10 or fewer employees?

Question 4

Is the partial exemption for size based on the size of my entire company or on the size of an individual business establishment?

Answer 4

The partial exemption for size is based on the number of employees in the entire company.

Question 5

How do I determine the size of my company to find out if I qualify for the partial exemption for size?

Answer 5

To determine if you are exempt because of size, you need to determine your company’s peak employment during the last calendar year. If you had no more than 10 employees at any time in the last calendar year, your company qualifies for the partial exemption for size.

Question 6

What are the partial exemptions for establishments in certain industries?

Answer 6

1. If your business establishment is classified in a specific low hazard retail, service, finance, insurance or real estate industry listed in Appendix A to this Subpart B, you do not need to keep OSHA injury and illness records unless the government asks you to keep the records under Section 1904.41 or Section 1904.42. However, all employers must report to OSHA any workplace incident that results in a fatality or the hospitalization of three or more employees
2. If one or more of your company’s establishments are classified in a non-exempt industry, you must keep OSHA injury and illness records for all of such establishments unless your company is partially exempted because of size under Section 1904.1

Question 7

Does the partial industry classification exemption apply only to business establishments in the retail, services, finance, insurance or real estate industries (SICs 52-89)?

Answer 7

Yes, business establishments classified in agriculture; mining; construction; manufacturing; transportation; communication; electric, gas and sanitary services; or wholesale trade are not eligible for the partial industry classification exemption.

Question 8

Is the partial industry classification exemption based on the industry classification of my entire company or on the classification of individual business establishments operated by my company?

Answer 8

The partial industry classification exemption applies to individual business establishments. If a company has several business establishments engaged in different classes of business activities, some of the company’s establishments may be required to keep records, while others may be exempt.

Question 9

How do I determine the Standard Industrial Classification code for my company or for individual establishments?

Answer 9

You determine your Standard Industrial Classification (SIC) code by using the Standard Industrial Classification Manual, Executive Office of the President, Office of Management and Budget. You may contact your nearest OSHA office or State agency for help in determining your SIC.

Question 10

How can I get help to find my SIC Code and determine if I’m partially exempt from the recordkeeping rule?

Answer 10

You can access the statistics section of OSHA’s internet home page, at http://www.osha.gov/oshstats/. Go to the website and choose SIC Manual and follow the directions. If you still cannot determine your SIC code, you can call an OSHA area office, or, if you are in a state with an OSHA-approved state plan, call your State Plan office. See the OSHA Office Directory.

Question 11

Do States with OSHA-approved State plans have the same industry exemptions as Federal OSHA?

Question 12

Do professional sports teams qualify for the partial industry exemption in section 1904.2?

Answer 12

No. Only those industry classifications listed in Appendix A to Subpart B qualify for the partial industry exemption in section 1904.2. Professional sports teams are classified under Standard Industrial Classification (SIC) code 794, which is not one of the listed exempt classifications.

Question 13

Give an overview of recordkeeping under the requirements of other Federal agencies

Answer 13

Section 1904.3 of the final rule provides guidance for employers who are subject to the occupational injury and illness recording and reporting requirements of other Federal agencies. Several other Federal agencies have similar requirements, such as the Mine Safety and Health Administration (MSHA), the Department of Energy (DOE), and the Federal Railroad Administration (FRA). The final rule at section 1904.3 tells the employer that OSHA will accept these records in place of the employer’s Part 1904 records under two circumstances: (1) if OSHA has entered into a memorandum of understanding (MOU) with that agency that specifically accepts the ther agency’s records, the employer may use them n place of the OSHA records, or (2) if the other gency’s records include the same information equired by Part 1904, OSHA would consider them a acceptable substitute.

Question 14

What are the basic recording criteria?

Answer 14

1. Is work-related; and
2. Is a new case; and
3. Meets one or more of the general recording riteria of Section 1904.7 or the application to specific ases of Section 1904.8 through Section 1904.11.

Question 15

What sections of this rule describe recording criteria for recording work-related injuries and illnesses?

Answer 15

(i) Determination of work-relatedness. See Section
1904. 5.
(ii) Determination of a new case. See Section
1904. 6.
(iii) General recording criteria. See Section 1904.7.
(iv) Additional criteria. (Needlestick and sharps injury cases, tuberculosis cases, hearing loss cases, medical removal cases, and musculoskeletal disorder cases). See Section 1904.8 through Section 1904.11.

Question 16

How do I decide whether a particular injury or illness is recordable?

Answer 16

1. Did the employee experience and injury or illness?
2. Is the injury or illness work-related?
3. Is the injury or illness a new case?
4. If not, update the previously recorded injury or illness if necessary.
5. If so, then does the injury or illness meet the general recording criteria or the apllication to specific cases?
6. If so, then record it.

Question 17

Does an employee report of an injury or illness establish the existence of the injury or illness for recordkeeping purposes?

Answer 17

No. In determining whether a case is recordable, the employer must first decide whether an injury or illness, as defined by the rule, has occurred. If the employer is uncertain about whether an injury or illness has occurred, the employer may refer the employee to a physician or other health care professional for evaluation and may consider the health care professional’s opinion in determining whether an injury or illness exists. [Note: If a physician or other licensed health care professional diagnoses a significant injury or illness within the meaning of Section1904.7(b)(7) and the employer determines that the case is work-related, the case must be recorded.]

Question 18

How do you determine work-relatedness?

Answer 18

You must consider an injury or illness to be workrelated if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in Section 1904.5(b)(2) specifically applies.

Question 19

What is a work environment?

Question 20

Are there situations where an injury or illness occurs in the work environment and is not considered work-related?

Answer 20

Yes, an injury or illness occurring in the work environment that falls under one of the following exceptions is not work-related, and therefore is not recordable.

1. At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.
2. The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.
3. The injury or illness results solely from voluntary participation in a wellness program or ina medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.
4. The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the employer’s premises or brought in). For example, if the employee is injured by choking on a sandwich while in the employer’s establishment, the case would not be considered work-related.
5. The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned working hours.
6. The injury or illness is solely the result of personal grooming, self medication for a non-workrelated condition, or is intentionally self-inflicted.
7. The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.
8. The illness is the common cold or flu (Note: contagious diseases such as tuberculosis, brucellosis,hepatitis A, or plague are considered work-related if the employee is infected at work).
9. The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is workrelated.

Question 21

How do I handle a case if it is not obvious whether the precipitating event or exposure occurred in the work environment or occurred away from work?

Answer 21

In these situations, you must evaluate the employee’s work duties and environment to decide whether or not one or more events or exposures in the work environment either caused or contributed to the resulting condition or significantly aggravated a preexisting condition.

Question 22

How do I know if an event or exposure in the work environment “significantly aggravated” a preexisting injury or illness?

Answer 22

A preexisting injury or illness has been significantly aggravated, for purposes of OSHA injury and illness recordkeeping, when an event or exposure in the work environment results in any of the following:

(i) Death, provided that the preexisting injury or illness would likely not have resulted in death but for the occupational event or exposure.
(ii) Loss of consciousness, provided that the preexisting injury or illness would likely not have resulted in loss of consciousness but for the occupational event or exposure.
(iii) One or more days away from work, or days of restricted work, or days of job transfer that otherwise would not have occurred but for the occupational event or exposure.
(iv) Medical treatment in a case where no medical treatment was needed for the injury or illness before the workplace event or exposure, or a change in medical treatment was necessitated by the workplace event or exposure.

Question 23

Which injuries and illnesses are considered pre-existing conditions?

Answer 23

An injury or illness is a preexisting condition if it resulted solely from a non-work-related event or exposure that occurred outside the work environment.

Question 24

How do I decide whether an injury or illness is work-related if the employee is on travel status at the time the injury or illness occurs?

Answer 24

Injuries and illnesses that occur while an employee is on travel status are work-related if, at the time of the injury or illness, the employee was engaged in work activities “in the interest of the employer.” Examples of such activities include travel to and from customer contacts, conducting job tasks, and entertaining or being entertained to transact, discuss, or promote business (work-related entertainment includes only entertainment activities being engaged in at the direction of the employer). Injuries or illnesses that occur when the employee is on travel status do not have to be recorded if they meet one of the exceptions listed below.

Question 25

How do I decide if a case is work-related when the employee is working at home?

Answer 25

Injuries and illnesses that occur while an employee is working at home, including work in a home office, will be considered work-related if the injury or illness occurs while the employee is performing work for pay or compensation in the home, and the injury or illness is directly related to the performance of work rather than to the general home environment or setting. For example, if an employee drops a box of work documents and injures his or her foot, the case is considered work-related. If an employee’s fingernail is punctured by a needle from a sewing machine used to perform garment work at home, becomes infected and requires medical treatment, the injury is considered work-related. If an employee is injured because he or she trips on the family dog while rushing to answer a work phone call, the case is not considered work-related. If an employee working at home is electrocuted because of faulty home wiring, the injury is not considered work-related.

Question 26

If a maintenance employee is cleaning the parking lot or an access road and is injured as a result, is the case work-related?

Answer 26

Yes, the case is work-related because the employee is injured as a result of conducting company business in the work environment. If the injury meets the general recording criteria of Section 1904.7 (death, days away, etc.), the case must be recorded.

Question 27

Are cases of workplace violence considered work-related under the new Recordkeeping rule?

Question 28

What activities are considered “personal grooming” for purposes of the exception to the geographic presumption of work-relatedness in section 1904.5(b)(2)(vi)?

Answer 28

Personal grooming activities are activities directly related to personal hygiene, such as combing and drying hair, brushing teeth, clipping fingernails and the like. Bathing or showering at the workplace when necessary because of an exposure to a substance at work is not within the personal grooming exception in section 1904.5(b)(2)(vi). Thus, if an employee slips and falls while showering at work to remove a contaminant to which he has been exposed at work, and sustains an injury that meets one of the general recording criteria listed in section 1904.7(b)(1), the case is recordable.

Question 29

What are “assigned working hours” for purposes of the exception to the geographic presumption in section 1904.5(b)(2)(v)?

Answer 29

“Assigned working hours,” for purposes of section 1904.5(b)(2)(v), means those hours the employee is actually expected to work, including overtime.

Question 30

What are “personal tasks” for purposes of the exception to the geographic presumption in section 1904.5(b)(2)(v)?

Answer 30

“Personal tasks” for purposes of section 1904.5(b)(2)(v) are tasks that are unrelated to the employee’s job. For example, if an employee uses a company break area to work on his child’s science project, he is engaged in a personal task.

Question 31

If an employee stays at work after normal work hours to prepare for the next day’s tasks and is injured, is the case work-related? For example, if an employee stays after work to prepare air-sampling pumps and is injured, is the case work-related?

Answer 31

A case is work-related any time an event or exposure in the work environment either causes or contributes

Question 32

If an employee voluntarily takes work home and is injured while working at home, is the case recordable?

Question 33

If an employee’s pre-existing medical condition causes an incident which results in a subsequent injury, is the case work-related? For example, if an employee suffers an epileptic seizure, falls, and breaks his arm, is the case covered by the exception in section 1904.5(b)(2)(ii)?

Answer 33

Neither the seizures nor the broken arm are recordable. Injuries and illnesses that result solely from non-work-related events or exposures are not recordable under the exception in section 1904.5(b)(2)(ii). Epileptic seizures are a symptom of a disease of nonoccupational origin, and the fact that they occur at work does not make them work-related. Because epileptic seizures are not work-related, injuries resulting solely from the seizures, such as the broken arm in the case in question, are not recordable.

Question 34

This question involves the following sequence of events: Employee A drives to work, parks her car in the company parking lot and is walking across the lot when she is struck by a car driven by employee B, who is commuting to work. Both employees are seriously injured in the accident. Is either case work-related?

Answer 34

Neither employee’s injuries are recordable. While the employee parking lot is part of the work environment under section 1904.5, injuries occurring there are not work-related if they meet the exception in section 1904.5(b)(2)(vii). Section 1904.5(b)(2)(vii) excepts injuries caused by motor vehicle accidents occurring on the company parking lot while the employee is commuting to and from work. In the case in question, both employees’ injuries resulted from a motor vehicle accident in the company parking lot while the employees were commuting. Accordingly, the exception applies.

Question 35

How does OSHA define a “company parking lot” for purposes of Recordkeeping?

Answer 35

Company parking lots are part of the employer’s premises and therefore part of the establishment. These areas are under the control of the employer, i.e. those parking areas where the employer can limit access (such as parking lots limited to the employer’s employees and visitors). On the other hand, a parking area where the employer does not have control such as a parking lot outside of a building shared by different employers, or a public parking area like those found at a mall or beneath a multi-employer office building) would not be considered part of the employers establishment (except for the owner of the building or mall), and therefore not a company parking lot for purposes of OSHA recordkeeping.

Question 36

An employee experienced an injury or illness in the work environment before they had “clocked in” for the day. Is the case considered work- related even if that employee was not officially “on the clock” for pay purposes?

Answer 36

Yes. For purposes of OSHA recordkeeping, injuries and illnesses occurring in the work environment are considered work-related. Punching in and out with a time clock (or signing in and out) does not affect the outcome for determining work-relatedness. If the employee experienced a work-related injury or illness, and it meets one or more of the general recording criteria under section 1904.7, it must be entered on the employer’s OSHA 300 log.

Question 37

Is work-related stress recordable as a mental illness case?

Question 38

If an employee dies or is injured or infected as a result of terrorist attacks, should it be recorded on the OSHA Injury and Illness Log? Should it be reported to OSHA?

Answer 38

Yes, injuries and illnesses that result from a terrorist event or exposure in the work environment are considered work-related for OSHA recordkeeping purposes. OSHA does not provide an exclusion for violence- related injury and illness cases, including injuries and illnesses resulting from terrorist attacks. Within eight (8) hours after the death of any employee from a work-related incident or the in-patient hospitalization of three or more employees as a result of a work-related incident, an employer must orally report the fatality/multiple hospitalization by telephone or in person to the OSHA Area that is nearest to the site of the incident. An employer may also use the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742).

Question 39

How do I make a determination about new cases?

Answer 39

You must consider an injury or illness to be a “new case” if: 1. The employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body, or 2. The employee previously experienced a recorded injury or illness of the same type that affected the same part of the body but had recovered completely (all signs and symptoms had disappeared) from the previous injury or illness and an event or exposure in the work environment caused the signs or symptoms to reappear.

Question 40

When an employee experiences the signs or symptoms of a chronic work-related illness, do I need to consider each recurrence of signs or symptoms to be a new case?

Answer 40

No, for occupational illnesses where the signs or symptoms may recur or continue in the absence of an exposure in the workplace, the case must only be recorded once. Examples may include occupational cancer, asbestosis, byssinosis and silicosis.

Question 41

When an employee experiences the signs or symptoms of an injury or illness as a result of an event or exposure in the workplace, such as an episode of occupational asthma, must I treat the episode as a new case?

Answer 41

Yes, because the episode or recurrence was caused by an event or exposure in the workplace, the incident must be treated as a new case.

Question 42

May I rely on a physician or other licensed health care professional to determine whether a case is a new case or a recurrence of an old case?

Question 43

How is an employer to determine whether an employee has “recovered completely” from a previous injury or illness such that a later injury or illness of the same type affecting the same part of the body resulting from an event or exposureat work is a “new case” under section 1904.6(a)(2)? If an employee’s signs and symptoms disappear for a day and then resurface the next day, should the employer conclude that the later signs and symptoms represent a new case?

Answer 43

An employee has “recovered completely” from a previous injury or illness, for purposes of section 1904.6(a)(2), when he or she is fully healed or cured. The employer must use his best judgment based on factors such as the passage of time since the symptoms last occurred and the physical appearance of the affected part of the body. If the signs and symptoms of a previous injury disappear for a day only to reappear the following day, that is strong evidence the injury has not properly healed. The employer may, but is not required to, consult a physician or other licensed health care provider (PLHCP). Where the employer does consult a PLHCP to determine whether an employee has recovered completely from a prior injury or illness, it must follow the PLHCP’s recommendation. In the event the employer receives recommendations from two or more PLHCPs, the employer may decide which recommendation is the most authoritative and record the case based on that recommendation.

Question 44

How do I decide if a case meets one or more of the general recording criteria?

Answer 44

A work-related injury or illness must be recorded if it results in one or more of the following: (i) Death. See Section 1904.7(b)(2). (ii) Days away from work. See Section 1904.7(b)(3). (iii) Restricted work or transfer to another job. See Section 1904.7(b)(4). (iv) Medical treatment beyond first aid. See Section 1904.7(b)(5). (v) Loss of consciousness. See Section 1904.7(b)(6). (vi) A significant injury or illness diagnosed by a physician or other licensed health care professional. See Section 1904.7(b)(7).

Question 45

How do I record a work-related injury or illness that results in the employee’s death?

Answer 45

You must record an injury or illness that results in death by entering a check mark on the OSHA 300 Log in the space for cases resulting in death. You must also report any work-related fatality to OSHA within eight (8) hours, as required by Section 1904.39.

Question 46

How do I record a work-related injury or illness that results in days away from work?

Answer 46

When an injury or illness involves one or more days away from work, you must record the injury or illness on the OSHA 300 Log with a check mark in the space for cases involving days away and an entry of the number of calendar days away from work in the number of days column. If the employee is out for an extended period of time, you must enter an estimate of the days that the employee will be away, and update the day count when the actual number of days is known. (i) Do I count the day on which the injury occurred or the illness began? No, you begin counting days away on the day after the injury occurred or the illness began. (ii) How do I record an injury or illness when a physician or other licensed health care professional recommends that the worker stay at home but the employee comes to work anyway? You must record these injuries and illnesses on the OSHA 300 Log using the check box for cases with days away from work and enter the number of calendar days away recommended by the physician or other licensed health care professional. If a physician or other licensed health care professional recommends days away, you should encourage your employee to follow that recommendation. However, the days away must be recorded whether the injured or ill employee follows the physician or licensed health care professional’s recommendation or not. If you receive recommendations from two or more physicians or other licensed health care professionals, you may make a decision as to which recommendation is the most authoritative, and record the case based upon that recommendation. (iii) How do I handle a case when a physician or other licensed health care professional recommends that the worker return to work but the employee stays at home anyway? In this situation, you must end the count of days away from work on the date the physician or

Question 47

Do I count the day on which the injury occurred or the illness began?

Answer 47

No, you begin counting days away on the day after the injury occurred or the illness began.

Question 48

How do I record an injury or illness when a physician or other licensed health care professional recommends that the worker stay at home but the employee comes to work anyway?

Question 49

How do I handle a case when a physician or other licensed health care professional recommends that the worker return to work but the employee stays at home anyway?

Answer 49

In this situation, you must end the count of days away from work on the date the physician or other licensed health care professional recommends that the employee return to work.

Question 50

How do I count weekends, holidays, or other days the employee would not have worked anyway?

Answer 50

You must count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether or not the employee was scheduled to work on those day(s). Weekend days, holidays, vacation days or other days off are included in the total number of days recorded if the employee would not have been able to work on those days because of a workrelated injury or illness.

Question 51

How do I record a case in which a worker is injured or becomes ill on a Friday and reports to work on a Monday, and was not scheduled to work on the weekend?

Answer 51

You need to record this case only if you receive information from a physician or other licensed health care professional indicating that the employee should not have worked, or should have performed only restricted work, during the weekend. If so, you must record the injury or illness as a case with days away from work or restricted work, and enter the day counts, as appropriate.

Question 52

How do I record a case in which a worker is injured or becomes ill on the day before scheduled time off such as a holiday, a planned vacation, or a temporary plant closing?

Answer 52

You need to record a case of this type only if you receive information from a physician or other licensed health care professional indicating that the employee should not have worked, or should have performed only restricted work, during the scheduled time off. If so, you must record the injury or illness as a case with days away from work or restricted work, and enter the day counts, as appropriate.

Question 53

Is there a limit to the number of days away from work I must count?

Answer 53

Yes, you may “cap” the total days away at 180 calendar days. You are not required to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work and/or days of job transfer or restriction. In such a case, entering 180 in the total days away column will be considered adequate.

Question 54

May I stop counting days if an employee who is away from work because of an injury or illness retires or leaves my company?

Question 55

If a case occurs in one year but results in days away during the next calendar year, do I record the case in both years?

Answer 55

No, you only record the injury or illness once. You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

Question 56

How do I record a work-related injury or illness that results in restricted work or job transfer?

Answer 56

When an injury or illness involves restricted work or job transfer but does not involve death or days away from work, you must record the injury or illness on the OSHA 300 Log by placing a check mark in the space for job transfer or restriction and an entry of the number of restricted or transferred days in the restricted workdays column.

Question 57

How do I decide if the injury or illness resulted in restricted work?

Answer 57

Restricted work occurs when, as the result of a work-related injury or illness: 1. You keep the employee from performing one or more of the routine functions of his or her job, or from working the full workday that he or she would otherwise have been scheduled to work; or 2. A physician or other licensed health care professional recommends that the employee not perform one or more of the routine functions of his or her job, or not work the full workday that he or she would otherwise have been scheduled to work.

Question 58

What is meant by “routine functions”?

Answer 58

For recordkeeping purposes, an employee’s routine functions are those work activities the employee regularly performs at least once per week.

Question 59

Do I have to record restricted work or job transfer if it applies only to the day on which the injury occurred or the illness began?

Answer 59

No, you do not have to record restricted work or job transfers if you, or the physician or other licensed health care professional, impose the restriction or transfer only for the day on which the injury occurred or the illness began.

Question 60

If you or a physician or other licensed health care professional recommends a work restriction, is the injury or illness automatically recordable as a “restricted work” case?

Answer 60

No, a recommended work restriction is recordable only if it affects one or more of the employee’s routine job functions. To determine whether this is the case, you must evaluate the restriction in light of the routine functions of the injured or ill employee’s job. If the restriction from you or the physician or other licensed health care professional keeps the employee from performing one or more of his or her routine job functions, or from working the full workday the injured or ill employee would otherwise have worked, the employee’s work has been restricted and you must record the case.

Question 61

How do I record a case where the worker works only for a partial work shift because of a work-related injury or illness?

Question 62

If the injured or ill worker produces fewer goods or services than he or she would have produced prior to the injury or illness but otherwise performs all of the routine functions of his or her work, is the case considered a restricted work case?

Answer 62

No, the case is considered restricted work only if the worker does not perform all of the routine functions of his or her job or does not work the full shift that he or she would otherwise have worked.

Question 63

How do I handle vague restrictions from a physician or other licensed health care professional, such as that the employee engage only in “light duty” or “take it easy for a week”?

Answer 63

If you are not clear about the physician or other licensed health care professional’s recommendation, you may ask that person whether the employee can do all of his or her routine job functions and work all of his or her normally assigned work shift. If the answer to both of these questions is “Yes,” then the case does not involve a work restriction and does not have to be recorded as such. If the answer to one or both of these questions is “No,” the case involves restricted work and must be recorded as a restricted work case. If you are unable to obtain this additional information from the physician or other licensed health care professional who recommended the restriction, record the injury or illness as a case involving restricted work.

Question 64

What do I do if a physician or other licensed health care professional recommends a job restriction meeting OSHA’s definition, but the employee does all of his or her routine job functions anyway?

Answer 64

You must record the injury or illness on the OSHA300 Log as a restricted work case. If a physician orother licensed health care professional recommendsa job restriction, you should ensure thatthe employee complies with that restriction. If youreceive recommendations from two or morephysicians or other licensed health care professionals,you may make a decision as to which recommendationis the most authoritative, and record the case based upon that recommendation.

Question 65

How do I decide if an injury or illness involved a transfer to another job?

Answer 65

If you assign an injured or ill employee to a job other than his or her regular job for part of the day, the case involves transfer to another job. Note: This does not include the day on which the injury or illness occurred.

Question 66

Are transfers to another job recorded in the same way as restricted work cases?